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Question #161

According to the Second European Union Money Laundering Directive, what may knowledge of criminal conduct be inferred from?

A . Subjective, factual circumstances
B . Objective, factual circumstances
C . Objective, non-factual circumstances
D . Subjective, non-factual circumstances

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Question #162

The goal of the Egmont Group of Financial Intelligence Units (FIUs) is to provide a forum for FIUs to: (Select Three.)

A . Improve global cooperation between FIUs.
B . Sign memoranda of cooperation that recognize and allow room for case-by-case solutions to specific problems.
C . Securely share sensitive information in the fight against money laundering and the financing of terrorism.
D . Propose legislation to combat financial crime, including money laundering and the financing of terrorism.
E . Establish an environment to foster trust among countries.

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Question #162

The goal of the Egmont Group of Financial Intelligence Units (FIUs) is to provide a forum for FIUs to: (Select Three.)

A . Improve global cooperation between FIUs.
B . Sign memoranda of cooperation that recognize and allow room for case-by-case solutions to specific problems.
C . Securely share sensitive information in the fight against money laundering and the financing of terrorism.
D . Propose legislation to combat financial crime, including money laundering and the financing of terrorism.
E . Establish an environment to foster trust among countries.

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Question #164

An oil exploration company based in France does business with oil refineries in Iran, which is subject to comprehensive Office of Foreign Assets Control (OFAC) sanctions.

What type of OFAC sanctions should be imposed against the French company?

A . Sectoral
B . Country-based
C . Secondary
D . List-based

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Question #165

What are three potential issues for foreign financial institutions maintaining correspondent accounts with U.S. banks under the Patriot Act? Choose 3 answers

A . Cancellation of correspondent banking relationships
B . Forfeiture of funds in a U.S. interbank account
C . Prohibition of correspondent accounts for shell banks
D . U.S. residents maintaining private banking accounts

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Richtige Antwort: A, B, C
A, B, C

Explanation:

The Patriot Act, enacted in 2001, introduced several provisions to enhance the anti-money laundering and counter-terrorist financing (AML/CFT) measures for U.S. banks and their foreign correspondent relationships. Some of the potential issues for foreign financial institutions (FFIs) maintaining correspondent accounts with U.S. banks under the Patriot Act are:

Cancellation of correspondent banking relationships: The Patriot Act requires U.S. banks to conduct due diligence and enhanced due diligence on their foreign correspondent accounts, and to terminate any account that poses a significant risk of money laundering or terrorist financing. This may result in the cancellation of correspondent banking relationships with FFIs that do not meet the U.S. standards or cooperate with the U.S. authorities. The loss of correspondent banking relationships may affect the FFIs’ ability to access the U.S. financial system and provide services to their customers. Forfeiture of funds in a U.S. interbank account: The Patriot Act authorizes the U.S. government to seize and forfeit any funds in a U.S. interbank account that are involved in or traceable to money laundering or terrorist financing activities. This means that FFIs may face the risk of losing their funds in a U.S. interbank account if they or their customers are suspected or accused of engaging in illicit activities. The forfeiture of funds may have significant financial and reputational consequences for the FFIs and their customers.

Prohibition of correspondent accounts for shell banks: The Patriot Act prohibits U.S. banks from establishing or maintaining correspondent accounts for shell banks, which are banks that have no physical presence in any country and are not affiliated with a regulated financial group. This means that FFIs that are shell banks or have relationships with shell banks cannot access the U.S. financial system through correspondent accounts. The prohibition of correspondent accounts for shell banks aims to prevent the use of shell banks as vehicles for money laundering and terrorist financing.

Reference: CAMS Study Guide, 6th Edition, Chapter 4: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), pp. 81-841

USA PATRIOT Act, Title III: International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001, Sections 312, 319, and 3132

Wolfsberg Anti-Money Laundering Principles for Correspondent Banking, October 2014, pp. 3-43

Reference: http://www.ffiec.gov/bsa_aml_infobase/pages_manual/olm_027.htm

Question #166

When considering sharing information across the institution or within the same jurisdiction, what is the key legal issue that poses challenges to sharing customer-related information?

A . Data protection and privacy laws
B . Consumer protection laws
C . Conflicting AML regulations
D . Technological inconsistencies and challenges

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Question #167

How does the Egmont Group assist financial intelligence unit members to accomplish their goals? (Select Three.)

A . Provides support to expand and systematize cooperation related to the reciprocal exchange of information
B . Fosters better and secure communication through the application of technology
C . Develops official lists of suspected terrorists on a globally coordinated basis by relevant authorities
D . Encourages operational autonomy of financial intelligence units
E . Maintains uniform global formats for funds transfers that assist in the detection of money laundering
F . Supplies information on the common money laundering tactics used by terrorists and financial supporters of terrorism

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Question #167

How does the Egmont Group assist financial intelligence unit members to accomplish their goals? (Select Three.)

A . Provides support to expand and systematize cooperation related to the reciprocal exchange of information
B . Fosters better and secure communication through the application of technology
C . Develops official lists of suspected terrorists on a globally coordinated basis by relevant authorities
D . Encourages operational autonomy of financial intelligence units
E . Maintains uniform global formats for funds transfers that assist in the detection of money laundering
F . Supplies information on the common money laundering tactics used by terrorists and financial supporters of terrorism

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Question #169

A popular restaurant in town has begun depositing less cash than it has in prior years. In a review of the customer’s accounts, you notice that credit card receipts have increased with no.

The account officer discovers that the restaurant has installed a privately-owned automated teller machine (ATM) onsite and has begun construction on a patio dining area.

Which red flag should trigger additional investigation?

A . Privately-owned ATM
B . Lower cash deposits
C . Increased credit card receipts
D . Construction of the new patio dining area

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Question #170

Which assessments are involved in the processes of mutual evaluation and follow-up by the FATF?

A . Risk assessments and technical standards assessments
B . Technical compliance assessments and effectiveness assessment
C . Sanction risk assessments and the country’s National Risk Assessment
D . Country audit assessments and transaction monitoring assessments

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